Exchange of Information Capabilities Are Underutilized by the Internal Revenue Service

The Commissioner, Large Business and International (LB&I) Division, should conduct outreach to examination and collection field functions to alert the field on the availability and potential usefulness of automatic data provided by treaty partners in examination and collection efforts that can be gained by requesting and obtaining access to the Easy Search tool.

The Commissioner, Large Business and International (LB&I) Division, should expand upon the AEOI Program section of the Internal Revenue Manual (IRM) 4.60.1, International Procedures - Exchange of Information, to add recordkeeping requirements to track the incoming and outgoing records and those made available on the AEOI database.

The Commissioner, Large Business and International (LB&I) Division, should create procedures (e.g., written guidance and/or desktop procedures) for AEOI personnel that: 1) allows AEOI personnel to accurately track the data and/or record counts received by country; 2) track the data by country that contractor uploaded to the AEOI database; and 3) monitor the difference in received and posted record counts by country to identify and resolve upload issues in a timely fashion.

The Deputy Commissioner for Services and Enforcement should reinforce the IRS's FY 2016 international collection strategy related to the MCAR Program to address the importance of issuing MCARs when warranted as an additional collection tool, and prioritize the timely processing of outgoing MCAR requests to maximize the use of limited resources.

The Deputy Commissioner for Services and Enforcement should enhance revenue officers' awareness of tools to explore international asset identification.